Privacy Policy

RETURN ON INVESTMENT LTD PRIVACY POLICY

Introduction

Welcome to Return on Investment Ltd’s privacy policy.

Return on Investment Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or otherwise share your personal data with us, and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [LINK]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important Information and Who We Are
The Data We Collect About You
How Is Your Personal Data Collected?
How We Use Your Personal Data
Disclosures of Your Personal Data
International Transfers
Data Security
Data Retention
Your Legal Rights
Your Legal Rights

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Return on Investment Ltd collects and processes your personal data when you use our website or otherwise share your personal data with us, including any data you may provide when you submit an enquiry via our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This privacy policy provides information on the personal data we process in respect of the following categories of individuals:

employees or other representatives of our clients and prospective clients, including automotive businesses, dealerships and leasing companies, whom we provide services to or intend to provide services to (referred to as Client Contacts in this privacy policy);
customers and prospective customers of our clients (and, where relevant, their friends, family or other associated contacts) (referred to as Customers in this privacy policy);
employees or other representatives of our suppliers;
users of our website.

Controller

Return on Investment Ltd is the controller and responsible for your personal data (referred to as ROI, we, us or our in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your Legal Rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Return on Investment Ltd

Email address: dpo@roiltd.co.uk

Postal address: Return on Investment Ltd, Pepper House, Market Street, Nantwich, CW5 5DQ

Telephone number: 01270 610400 (please ask to speak to the DPO)

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 24th Jan. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

identity information such as your first name, maiden name, last name, marital status, title, date of birth, gender and copy identification documents such as passports, driving licences and utility bills;
contact information such as your address, email address, telephone numbers and job title;
vehicle information, where you are a Customer, such as your vehicle registration number (VRN), vehicle information number (VIN) and date of purchase;
financial information such as bank account number, sort code, payment card details, credit check results and billing address;
transaction information such as:
details about payments to and from you;
details of products and services you have purchased from us or from our client;
technical information such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website;
user profile information such as your username and password, purchases or orders made by you (either to us or to our client), your interests, preferences, feedback and survey responses;
usage information such as:
information about how you use our website;
information about how you use our products and services, or the products and services of our clients;
analytical information about your engagement with our client and the communications which we send to you on their behalf;
marketing and communications information such as your preferences in receiving marketing from us and/or our client and your communication preferences.
CCTV images are collected by our system and typically kept for no more than 31 days unless they are to be used in criminal or disciplinary proceedings.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also, in certain circumstances (for example, when we support our clients with their events), collect some Special Category Data, including information about your health (such as any dietary requirements and information relating to medical conditions and any disabilities). However, we will only process Special Category Data in circumstances where we have (or our client has) your consent and where such processing is necessary so that we can provide our services (or our client’s services) to you, where we have a legitimate interest in doing so (for example, to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client) and/or where we have otherwise obtained your explicit consent to such processing. We do not collect any information about your race or ethnicity, sexual orientation, political opinions, trade union membership, religious or philosophical beliefs or criminal convictions and offences.

When you provide personal information to us which does not relate directly to you but is personal information of a third party (for example, the name and contact details of the person who you identify as your emergency contact and/or, where you are attending one of our client’s events, the name, contact details and dietary requirements of your plus-one), you confirm that you are authorised to provide such information and shall ensure that this privacy policy is brought to the attention of such individuals so that those individuals understand how their data will be processed by us. We will hold and use such personal information in accordance with this privacy policy and data protection laws and such individuals shall be deemed to be Customers for the purposes of this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
request services from us;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us;
automated technologies or interactions. As you interact with our website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details;
clients. We will access and process personal data about you which has been collected and stored by our clients, where our clients instruct us to provide services which require us to process your personal data;
third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as:
analytics providers such as Google based outside the EU;
search information providers such as Google based outside the EU.
providers of technical, payment and delivery services;
data brokers or aggregators;
publicly available sources such as Companies House, business directories and social media platforms.
CCTV images collected on-site that are situated at entry/exit points and data processing areas.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into with you or the business which you represent;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
where we need to comply with a legal obligation.

Click here (Glossary) to find out more about the types of lawful basis that we will rely on to process your personal data.

If you are a Customer, we may rely upon consent as a lawful basis for processing, where you have given consent to our client and we are contacting you on behalf of that client. You have the right to withdraw consent to processing and marketing at any time by contacting us or our client.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

The tables are split into categories based on your relationship with us. Please review the tables which are applicable to you.

Client Contacts

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To register you (or the client which you represent) as a new client

(a) Performance of a contract

(b) Necessary to comply with a legal obligation

To process and deliver your request for our services including:

(a) manage payments, fees and charges

(b) collect and recover money owed to us (a) Performance of a contract

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you (or the client which you represent) which will include:

(a) notifying you about changes to our terms or privacy policy

(b) asking you to leave a review or take a survey (a) Performance of a contract

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, client relationships and experiences Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you (or the client which you represent) Necessary for our legitimate interests (to develop our products/services and grow our business and to administer and provide you with information relating to pre-sales agreements with our clients)

Customers (where we are acting as a data processor and process your personal data on behalf of our applicable client)

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To send marketing communications to you on behalf of our client (which may be tailored to you based on your interests or previous purchases) Consent (collected by our applicable client)

To notify you about changes to our terms or privacy policy

Necessary to comply with a legal obligation

To enable you to partake in a prize draw, competition or complete a survey

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our client’s products/services and report back to our client on this as part of services we provide to our client)

To ensure that our communications deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you on behalf of our client Necessary for our legitimate interests (to study how Customers use our client’s products/services, to report back to our client on this and to inform our client’s marketing strategy as part of services we provide to our client)

To use data analytics to help improve our client’s products/services, marketing, customer relationships and experiences (including for market research purposes and customer satisfaction surveys) Necessary for our legitimate interests (to define types of Customers for our client’s products and services and to inform our client’s marketing strategy as part of services we provide to our client)

To make suggestions and recommendations to you on behalf of our client about goods or services that may be of interest to you Necessary for our legitimate interests (to develop our client’s products/services and help grow their business, as part of services we provide to our client)

To book any test drive or otherwise provide, manage and respond to any requests that you have made on behalf of our client Necessary for our legitimate interests (to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client)

To administer and provide you with information relating to pre-sales agreements with our clients Necessary for our legitimate interests (to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client)

To provide you with quotations for business or private vehicle finance Necessary for our legitimate interests (to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client)

To respond to any customer service related enquiries Necessary for our legitimate interests (to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client)

To organise and provide invitations to our client’s events (which may include the collection of Special Category Data)

(a) Consent

(b) Necessary for our legitimate interests (to perform our client’s contractual commitments to you or to develop our client’s products/services and help grow their business, as part of services we provide to our client)

Suppliers (including sole traders and small partnerships, and where our supplier is a company, including employees or other representatives)

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To register you as a new supplier

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to ensure that our suppliers are creditworthy)

To perform our contract with you, including paying you Performance of a contract with you

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Users of our website

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To respond to any query which you submit via our ‘Contact Us’ form Necessary for our legitimate interests (to respond to queries about our business, products and services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how people use our website, to develop it, to grow our business and to inform our marketing strategy)

Promotional offers from us

If you are a Client Contact, we may use your personal data to form a view on what we think you may want or need, or what may be of interest to you or the client which you represent. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Promotional offers from our clients

If you are a Customer, on behalf of our clients, we may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us (on behalf of our clients) if you have requested information from our clients or purchased goods or services from our clients and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes (other than the client with whom you have an ongoing relationship or have contacted about their products or services, where applicable).

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us, or (where applicable) the client whom we contact you on behalf of.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us/our client as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the tables in section 4 above.

External Third Parties as set out in the Glossary;
our relevant client, where you are a Customer;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients for six years after they cease being clients for tax purposes. If you are a Customer, we will return to our client or destroy your personal data at the end of our contract with them. However, our client may retain your personal data for a longer period in line with their own privacy and data retention policies.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties:

service providers acting as processors based in the EU and in the USA (such as Amazon Web Services) who provide IT and system administration services;
professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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